William Kingston personally sued the IRS in U. S. Tax Court. Instead of paying the $50,000+ the IRS alleged he owed, he paid nothing and was awarded Litigation Costs under Sec. 7430 of the Internal Revenue Tax Code.      For assistance with Tax problems nothing will take the place of  personal service by a qualified person with a PROVEN record of success in dealing with the IRS.         The IRS alleged that Kingston owed over $50,000 in tax, interest and penalties in attempting to disallow tax deductions from his investment in a limited partnership.         Kingston believed the IRS was wrong and Without An Attorney  successfully defeated them in U. S. Tax Court.   With his research and analysis, preparation of all pleadings  and his presentation to the tax court, he convinced the judges that the IRS was wrong.  Instead of owing the alleged $50,000+, he owed nothing and was issued a refund by the IRS.         There is not another CPA in the country who had personally brought the IRS into U. S. Tax Court and prevailed in such a complex case.  The U. S. Tax Court agreed with Kingston that the IRS's position "was not Substantially Justified and had no basis in fact or law" and awarded him Litigation Costs.  See the Opinions of the tax court, links to the published Opinions can be found on the next page.       Details of Kingston's successful action against the IRS were published by various publications, see the Wall Street Journal and Crain's Detroit Business articles that follow and highlights the case.        Kingston will personally represent you in solving your tax problems, he is able to deal will all levels of the IRS to negotiate and settle your tax issues on the most favorable terms possible.            There are many "Tax Resolution" organizations trying to cash in on the latest "craze" of "representing taxpayers before the IRS."-  Many people that have used them for representation were unhappy with their services, because of their high fees, the lack of personal attention and the lack of success that was promised (See page 5)      Kingston can help solve your tax problems and obtain the most favorable outcome possible- as he did in his own case as mentioned above.  In that breakthrough victory the IRS originally wanted in excess of $50,000 and instead they ended up issuing Kingston a refund. In order to successfully challange and prevail over the IRS,  Kingston personally performed all of the research and analysis, conducted all of the negotiations, prepared all legal document and appeared before the U S Tax Court-- all without the services of an attorney. The results of his successful litigation were published as Kingston v. Commissioner, Tax Court Memorandums, 1997-512, and 1998-119- see the Tax Court Decision Page on this site.      A UNIQUE VICTORY- Regarding the Hambrose Leasing Limited Partnerships Issue-      Kingston was the only partner, out of more than 1,000 limited partners that was allowed the tax deductions to which the partners were entitled to. All of the other Hambrose Partners paid taxes, interest and penalties they did not owe as their deductions were disallowed. These partners, because of poor legal representation or presure from the IRS,  either settled with the IRS or litigated their case in U.S. Tax Court and lost, all making unnecessary payments to the IRS.      For help with your tax issues or problems contact William Kingston.  He  can help taxpayers residing anywhere in the country with services including- Tax Return Preparation - Filing Delinquent Returns - Review of Prior Returns- Overlooked Tax Deductions- Preparation and Filing of Amended Returns- IRS and State Audits - Lien, Levy & Garnishments Appeals and Removal- Installment Agreements - Offer in Compromise - Innocent Spouse Relief - Penalty Abatement -  IRS Appeals and Protests - Employee/Subcontractor Determinations -  Payroll Tax Issues - Overtime Issues -      Kingston has vast experience in various other types of financial matters, including Credit and Mortgage issues.      As an experience CPA with a proven record, in research, analysis and negotiation,  Mr. Kingston will help solve your  tax problems-- hopefully as successfully as he solved his own, in which he convinced the U S Tax Court that the IRS was wrong, so wrong that the Court even ordered the IRS to reimburse Kingston for his costs.      Review the pages of this website, you will find the Published Opinions of the  United States Tax Court on the above mentioned cases and a portion of his background. Feel free to contact Mr. Kingston for a free consultation. ____________________________________________________________________________________________________________ The following articles were published by the Wall Street Journal and Crain's Detroit Business and discussed William Kingston's victory over the IRS and the awarding of Litigation Costs under Sec 7430 of the IRS Code: ___________________________________________________________________________________________________________ Crain's Detroit Business              DETERMINED CPA BEATS IRS           IN LIMITED-PARTNERSHIP FIGHT By MATT ROUSH June 01, 1998      When it comes to fighting the Internal Revenue Service, William Kingston is a bit like the sole survivor of a plane crash.      The West Bloomfield Township CPA defeated the IRS in a dispute over that ubiquitous 1980s investment, the limited partnership, while fellow investors paid big penalties and interest, through lost court cases or settlements.      Kingston represented himself through the entire proceeding and even won a follow-up proceeding that requires the IRS to pay his out-of-pocket costs of $2,402 in fighting the IRS charges.      But unlike a plane crash survivor, Kingston maintains his victory has nothing to do with luck. He said his keys were persistence, careful research, a logical argument and the refusal to take so-called expert advice.      Kingston bought his investment in Hambrose Leasing 1985-3 L.P. in 1985. This partnership was part of a complex series of sale-and-leaseback transactions in which IBM mainframe computer equipment was leased to businesses, with the cash flow from the leases going back to the limited partners. The partnerships were led by general partner Barry Goldwater Jr., son of the former U.S. senator from Arizona.      The partnerships, as expected, lost money initially, and the limited partners were able to use the losses to offset other income on their tax returns. But the partnerships then were expected to recoup the losses as the equipment came off lease and was released.      However, shortly after the establishment of the partnerships, mainframe equipment was supplanted in the computer marketplace by personal computers linked by file servers. That slashed the amount the computers fetched on the market when the leases expired.      Kingston's original investment was $20,000, which he was never fully repaid. But the IRS, when it first came after him in 1994, was asking for nearly $60,000 in back taxes, penalties and interest.      That demand came after the IRS began auditing 13 of the 35 Hambrose partnerships in 1989. The IRS contended that the partnerships overall were a sham. The IRS lost that case in 1992 but then turned to the more than 1,000 limited partners over the more arcane issue of whether they were ever actually ``at risk'' in their investments.      The IRS' contention was that the limited partnerships were set up so that partners like Kingston never actually could lose money. For that reason, the partnership's losses could not be used to offset ordinary income, as Kingston had done on tax returns in 1985 and 1986.      However, Kingston contended that loan documents in the partnership clearly made the limited partners liable for money the partnership borrowed, and his share was $57,285. That meant he was truly at risk for even more than his atual investment, and thus, the deduction was legal.      After years of legal wrangling, and a one-day trial Sept. 16, 1996, in U.S. Tax Court in Detroit, a federal judge finally agreed. Special Trial Judge D. Irvin Couvillion issued a memorandum opinion Nov. 17 siding with Kingston. Tax Court Judge Thomas Wells concurred in a decision issued March 31.      Kingston said he spent more than 1,000 hours reviewing dozens of precedent-setting cases and studying the minutiae of the tax code as it affected his case. The reason he represented himself was simple: Hiring an expert tax attorney at $200 an hour or more likely would have cost him more than the $60,000 charge he faced.      ``I think the IRS counts on that fact when it tries to get people to settle,'' Kingston said.      Indeed, court records show that most of the Hambrose partners took up IRS settlement offers that cut the amount of penalties charged, thus avoiding expensive attorney fees. Only three Hambrose partners litigated, and of those three, only Kingston won.      But cost wasn't the only reason Kingston burned the midnight oil.      ``I just enjoy doing the research,'' he said. ``And I thought, why pay them if I thought they were wrong? I also thought it would help me work for my clients if I learned about Tax Court.''      Elizabeth Flores, the IRS attorney who unsuccessfully battled Kingston in court, declined to comment on the case, referring questions to the IRS' public relations staff, which also declined comment. The IRS had until last Sunday to appeal. http://www.crainsdetroit.com/article/19980601/SUB/806010879# HTTP://CRAINSDETROIT.COM   ________________________________________________________________________________